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FDIC Federal Register Citations



JERSEY SHORE STATE BANK

August 31, 2004

Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

RE: FDIC RIN #3064-AC50 Comments/Legal ESS

Dear Mr. Feldman:

The proposed rulemaking for CRA is a welcome foray into improving possibilities for community development activities, although it is somewhat anticlimactic in that it fails to effectively define the proposed system for assigning credits under the proposed ceilings. Certainly the proposal to move the large bank definition to over $1 billion in assets is timely and necessary. However, it offers no changes to banks over $1 billion in assets, while providing very little in the way of relief for banks $250 million to $1 billion.

The current rules already use the same criteria to assess the effectiveness of these banks' performance, with the exception of the proposal to expand the definition of community development to encompass those activities that benefit rural areas. While this will improve the ability of small rural institutions to make better use of available resources for their community development purposes, it is unclear how it will benefit urban institutions and others similarly situated. Perhaps the final rule could include additional credit for investments or services for these institutions, due to their direct competition with larger institutions for these activities.

With regard to the definition of "rural", perhaps those areas designated by the Rural Housing Service of the United States Department of Agriculture as eligible for RHS financing would be adequate or designate "rural" census tracts from time to time, allowing for current data to suffice for the determination.

Thank you for your consideration of our comments.

Sincerely,

Ronal A. Walko
President

John R. Frey
Chief Compliance Officer

 

Last Updated 09/10/2004 regs@fdic.gov

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